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Law School Case Brief

Taylor v. Alabama - 457 U.S. 687, 102 S. Ct. 2664 (1982)

Rule:

The Supreme Court of the United States holds that a confession obtained through custodial interrogation after an illegal arrest should be excluded unless intervening events break the causal connection between the illegal arrest and the confession so that the confession is sufficiently an act of free will to purge the primary taint. The Court has identified several factors that should be considered in determining whether a confession has been purged of the taint of the illegal arrest: the temporal proximity of the arrest and the confession, the presence of intervening circumstances, and, particularly, the purpose and flagrancy of the official misconduct. The State bears the burden of proving that a confession is admissible. 

Facts:

Defendant Omar Taylor was arrested, without a warrant, charged with robbing a grocery store, and given his Miranda warnings, all after an informant's tip implicated him. At the police station, Taylor was fingerprinted, readvised of his Miranda rights, questioned and placed in a line-up. The robbery victims were unable to identify Taylor in the lineup. Subsequently, the police told Taylor that his fingerprints matched those found at the scene of the crime, and after a short visit from his girlfriend and a male companion, he signed a waiver-of-rights form and a written confession, both of which were admitted to evidence at trial in Alabama state court. At trial, Taylor filed a motion to suppress his confession, arguing that his warrantless arrest was illegal because it was based on the informant's tip, which was insufficient to give the police probable cause to arrest, and thus the confession had to be suppressed as fruit of the illegal arrest. The trial court denied the motion, and Taylor was convicted. On appeal, the Alabama Court of Criminal Appeals reversed, holding that the confession should not have been admitted into evidence. The Supreme Court of Alabama reversed, finding that that any taint from Taylor's warrantless arrest was purged, and the confession was thus admissible. The State was granted a writ of certiorari. 

Issue:

Was Taylor's confession admissible as evidence?

Answer:

No.

Conclusion:

The Supreme Court of the United States reversed Taylor's conviction and remanded for further proceedings, concluding that Taylor's confession was the fruit of an illegal arrest, there was insufficient attenuation to break connection between the illegal arrest and the confession, and thus, the confession was inadmissible. The Court noted that a confession obtained through custodial interrogation, after an illegal arrest, should be excluded unless intervening events broke the causal connection between the illegal arrest and the confession so that the confession was sufficiently an act of free will to purge the primary taint. In Taylor's case, there was no meaningful intervening event where the State failed to explain how his five to ten minute visit with his girlfriend and a male companion, while he was in custody but before he confessed, and after which he immediately recanted his former statements that he knew nothing about the robbery and signed the confession, could possibly have contributed to his ability to consider carefully and objectively his options and to exercise his free will so as voluntarily to confess to the crime. The facts that the police did not physically abuse Taylor, that the confession may have been voluntary for purposes of the Fifth Amendment, and that Taylor had been given Miranda warnings three times, did not cure the illegality of the initial arrest.

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